Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined against petitioner, as a withholding agent, a deficiency in tax of $14,074.20 and 25 per cent addition of $3,518.55, for 1937, and a deficiency in tax of $7,253.08 and 25 per cent addition of $1,813.27, for 1938, in respect of amounts paid to a nonresident alien. The petitioner contends that the payments were not subject to withholding. All the facts are stipulated.
The petitioner...
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